News & Analysis as of

Disclosure Requirements NRSRO

King & Spalding

SEC Brings Action Against Morningstar Alleging Undisclosed CMBS Rating Adjustments

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On February 16, 2021, the SEC filed a litigated civil complaint in the Southern District of New York against Morningstar Credit Ratings LLC, a former Nationally Recognized Statistical Rating Organization (“NRSRO”) alleging...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Dorsey & Whitney LLP

SEC Sanctions Another Entity For Not Following Its Procedures

Dorsey & Whitney LLP on

A continuing focus of SEC enforcement is compliance by entities with their disclosed procedures. The Commission’s latest action in this regard resulted in the payment of $6 million by a Credit Rating Agency that not only...more

Morgan Lewis

New Credit Rating Agency Rules Offer Insight into Public Company Internal Controls

Morgan Lewis on

The SEC has adopted credit rating agency rules for Nationally Recognized Statistical Rating Organizations (NRSROs), which include requirements relating to NRSROs’ internal controls. The Dodd-Frank Act requires NRSROs to...more

Cadwalader, Wickersham & Taft LLP

At Long Last—SEC Adopts Final Regulation AB II

On August 27, 2014 the Securities and Exchange Commission (the “SEC”) approved final rules relating to asset-backed securities (“ABS”) disclosure and registration (the “Final Rules”). The Final Rules are contained in a final...more

Dechert LLP

Final REG AB Rules: Man Bites Dog

Dechert LLP on

I am congenitally pessimistic and some have, shockingly, called me cynical. Early last week, while we waited for Reg AB, I would have bet more than a dollar that there would have been a number of things in this final Rule...more

Goodwin

SEC Adopts Final Credit Rating Agency Rules

Goodwin on

The SEC adopted new rules and rule amendments (collectively, the “Final Rules”) that impose a range of additional requirements on credit rating agencies registered as nationally recognized statistical rating organizations...more

Dechert LLP

New Regulation AB II and NRSRO Rules Released

Dechert LLP on

The U.S. Securities Exchange Commission (the “SEC”) released new Regulation AB II Rules (the “Reg AB Rules”) and regulations relating to credit rating agencies (“the NRSRO Rules”) on August 27, 2014. The Reg AB Rules1 revise...more

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